Global Corporate Income Tax Matters Policy

Updated June 2019

Adobe’s Board of Directors oversees the management of the company’s business, driving effective decision‐making and performance, while serving as advocates for its stockholders to protect their long‐term interests. Adobe’s Audit Committee serves to assist the Board in fulfilling its responsibilities to oversee management’s financial, accounting and reporting processes, the Company’s system of internal accounting and financial controls, the Company’s enterprise risk management program, and the Company’s compliance with related legal, regulatory and ethical requirements. The Audit Committee’s scope of responsibility includes Adobe’s global tax matters, and specifically this policy, which it approved on June 24, 2019.

Adobe’s Chief Financial Officer signed this document below as an affirmation of this policy.

Adobe’s tax strategy is aimed at the full compliance with all relevant tax laws and regulations in every country and jurisdiction in which it operates. Moreover, Adobe strives to follow the best standards in the business community and aims to be recognized for its practices and programs on corporate and tax governance. Adobe’s risk profile is moderate and conservative. It is based on the implementation of prudent risk management, consistent with its commitment and obligation to protect the interests of the Company and its shareholders within a framework of support for the business strategy in the long term, while avoiding inefficiencies in the implementation of business decisions. Accordingly, and taking into account both the corporate interests of the Company and its shareholders, Adobe’s conduct in tax matters shall be governed by the following:

PRINCIPLES:

Full compliance with relevant tax laws.

Payment when due of all taxes required in accordance with relevant law, without incurring tax inefficiencies and undue tax burdens.

As part of our global tax strategy, Adobe does not intend to seek global tax rates lower than the U.S. corporate tax rate.

Implementation of a relevant arm’s‐length transfer pricing policies.

Our objectives include eliminating uncertainty where appropriate with regard to the interpretation of tax laws. This may include the use of tax forums, advance pricing agreements, and other cooperative mechanisms provided by jurisdictions, as well as the implementation of relationships with local tax authorities based on trust, integrity and transparency.

Cooperation with tax authorities in their audit activities in respect of Adobe companies, recognizing the legitimate right of the Company to disagree with tax authorities and to uphold its own position before Courts based on our interpretation of the law.

Adobe aims to continue its practice of having adequate control mechanisms in place to ensure the fulfillment of the preceding principles.

This policy has been approved by John Murphy, Executive Vice President and Chief Financial Officer for Adobe.